Case Information
*0 FILED IN 3rd COURT OF APPEALS AUSTIN, TEXAS 12/21/2015 5:19:48 PM JEFFREY D. KYLE Clerk CAUSE NO. 03-15-00744-CV THIRD COURT OF APPEALS 12/21/2015 5:19:48 PM JEFFREY D. KYLE AUSTIN, TEXAS 03-15-00744-CV *1 ACCEPTED [8332950] CLERK
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IN THE COURT OF APPEALS
FOR THE THIRD JUDICIAL DISTRICT
AUSTIN, TEXAS
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CHAMBERS-LIBERTY COUNTIES NAVIGATION DISTRICT, et al. ,
Appellants, v.
STATE OF TEXAS,
Appellee.
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APPELLANTS’ UNOPPOSED MOTION FOR EXTENSION
OF TIME TO FILE APPELLANTS’ BRIEF
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TO THE HONORABLE JUSTICES OF THE COURT OF APPEALS FOR THE
THIRD DISTRICT OF TEXAS:
The Chambers-Liberty Counties Navigation District (the “District”) and the
District’s Commissioners Terry Haltom, Allen Herrington, Ken Coleman, Ken
Mitchell, and Dave Wilcox (collectively, the “Commissioners” and together with
the District the “Appellants”), Appellants in the above styled and numbered cause,
move this Court to grant an extension of time to file Appellants’ Brief, and in
support thereof would respectfully show the Court as follow:
1. Appellants’ Brief is currently due on or before December 29, 2015.
2. Appellants seek a 24-day extension of time to file their Appellants’
Brief, which would make the Appellants’ Brief due on or before January 22, 2016.
3. This extension of time is necessary because the accelerated briefing
schedule would cause Appellants’ brief to be due during a time when Appellants
and their lawyers are on vacation for the Christmas holiday. Conversely, adhering
to the current briefing schedule would interfere with Appellee’s counsel’s holiday
over the New Year.
4. Counsel for Appellants has conferred with counsel for Appellee, and
Appellee does not oppose this Motion.
5. This is the first extension of time Appellants have sought for filing of
its Appellants’ Brief. This motion is not filed for the purpose of delay, but so that
justice may be done.
For these reasons, Appellants request that this Court grant Appellants’
Motion for Extension of Time to File Appellants’ Brief, so that the Appellants’
Brief will be due on or after January 22, 2016. Appellants also request any other
relief to which they may be entitled.
Respectfully submitted,
LLOYD GOSSELINK
ROCHELLE & TOWNSEND, P.C.
816 Congress Avenue, Suite 1900
Austin, Texas 78701
Telephone: (512) 322-5800
Facsimile: (512) 472-0532
/s/ Lambeth Townsend LAMBETH TOWNSEND State Bar No. 20167500 ltownsend@lglawfirm.com JAMES F. PARKER, III State Bar No. 24027591 jparker@lglawfirm.com NATHAN E. VASSAR State Bar No. 24079508 nvassar@lglawfirm.com ATTORNEYS FOR APPELLANTS CHAMBERS-LIBERTY COUNTIES NAVIGATION DISTRICT AND ITS COMMISSIONERS CERTIFICATE OF CONFERENCE
Pursuant to Tex. R. App. P. 10.1(a)(5), this certifies that I conferred with
counsel for Appellee, Craig Pritzlaff, regarding the merits of this motion, and
Appellee does not oppose this motion.
/s/ James F. Parker, III JAMES F. PARKER, III *4 CERTIFICATE OF SERVICE
I hereby certify that a true and correct copy of the foregoing document has
been sent to the following counsel of record, in accordance with the Texas Rules of
Appellate Procedure, via electronic transmission on this 21 st day of December,
2015:
Craig Pritzlaff ( craig.pritzlaff@texasattorneygeneral.gov )
Steven H. Lord, Jr. ( steven.lord@texasattorneygeneral.gov )
Office of the Attorney General of Texas
P.O. Box 12548, MC-066 Austin, Texas 78711-2548
ATTORNEYS FOR APPELLEE
THE STATE OF TEXAS
/s/ James F. Parker, III JAMES F. PARKER, III